Personal Injury Interrogatories to Plaintiff

					This Personal Injury Interrogatories to Plaintiff document sets forth many of the special
interrogatories that should be propounded on a plaintiff in a personal injury case.
Interrogatories are an integral part of conducting discovery, and this document will help
ensure that no information is overlooked. The propounding party can easily insert
specific terms into this document to make sure the end result is tailored to the party's
unique situation. This document should be used by defendants or their attorneys when
conducting discovery in a personal injury case.
PROPOUNDING PARTY:             ________________ [Instructions: Insert name of propounding
                               party]

RESPONDING PARTY:              ________________ [Instructions: Insert name of responding
                               party]

SET NUMBER:                    ________________ [Instructions: Since multiple sets of requests
                               are permitted, the User should set forth the number]



TO ALL PARTIES HEREIN AND THEIR RESPECTIVE ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE that Defendants, ________________ [Instructions: Insert name of
propounding party], hereby request that Plaintiff ________________ [Instructions: Insert
name of responding party] respond to the following interrogatories under oath, pursuant to
________________ [Instructions: Cite to governing law that permits the discovery demand].




DEFINITIONS

      1. The term “YOU” and “YOUR” refers to the responding party, Plaintiff
________________ [Instructions: Insert name of Plaintiff].

         2. The term “DOCUMENT” means a writing, as defined in ________________
[Instructions: Cite to relevant evidence code section in state that sets forth definition for
“document” or set forth definition in its entirety here], and includes the original or a copy of
handwriting, typewriting, printing, photostating, photographing, and every other means of
recording upon any tangible thing and form of communicating or representation, including
letters, words, pictures, sounds, or symbols, or combinations of them, including, but not limited
to, papers, money, agreements, contracts, checks, notes, bank notes, memoranda,
correspondence, letters, telegrams, statements, books, reports, studies, minutes, records,
accounting books, maps, plans, drawings, diagrams, photographs, analysis, surveys,
transcriptions, and recordings of which you have any knowledge or information, whether in your
possession or under your control or not, relating or pertaining in any way to the subject matters
in connection with which it is used, and includes, without limitation, originals, all file copies, and
all other copies, no matter how or by whom prepared, and all drafts prepared in connection with
such writings, whether used or not.

       3. The term “INCIDENT” refers to Plaintiff’s alleged injury at ________________
[Instructions: Insert location] on ________________ [Instructions: Insert date].
                                SPECIAL INTERROGATORIES:



SPECIAL INTERROGATORY NO. 1

        Where was YOUR place of residence at the time of the INCIDENT?



SPECIAL INTERROGATORY NO. 2

        Are YOU married to ________________ [Instructions: Insert name of spouse]?



SPECIAL INTERROGATORY NO. 3

         If YOUR response to the preceding interrogatory is yes, state the date and the place (i.e.
city, state, country) YOU were married.



SPECIAL INTERROGATORY NO. 4

       If YOUR response to the interrogatory No. 2 is yes, identify all DOCUMENTS which
support YOUR response.



SPECIAL INTERROGATORY NO. 5

     Please state the name, address and phone number of YOUR employer(s) at the time of the
INCIDENT.



SPECIAL INTERROGATORY NO. 6

        Please identify all DOCUMENTS which support or tend to support YOUR response to
Interrogatory No. 5.




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SPECIAL INTERROGATORY NO. 7

      Describe in detail the reason that YOU were at the location of the INCIDENT on
________________ [Instructions: Insert time and date]



SPECIAL INTERROGATORY NO. 8

        Were YOU performing work for any employer on the date of the INCIDENT?



SPECIAL INTERROGATORY NO. 9

        If YOUR response to the preceding Interrogatory is yes, please state YOUR job duties on
that date.



SPECIAL INTERROGATORY NO. 10

      If your response to Interrogatory No. 8 was “yes,” please state in detail who directed
YOU to perform work on the date of the INCIDENT.



SPECIAL INTERROGATORY NO. 11

      Do YOU contend YOU were employed by ________________ [Instructions: Insert
name of employer] on the date of the INCIDENT?



SPECIAL INTERROGATORY NO. 12

       If YOUR response to the precedent Interrogatory is yes, please state in detail the reason
for your contention.



SPECIAL INTERROGATORY NO. 13

      If YOUR response to the Interrogatory No. 11 is yes, please provide the name, telephone
number and address of the individuals who can support YOUR contention.




© Copyright 2012 Docstoc Inc.                                                                      4
SPECIAL INTERROGATORY NO. 14

        If YOUR response to the Interrogatory No. 11 is yes, please identify all DOCUMENTS
that support or tend to support YOUR contention.



SPECIAL INTERROGATORY NO. 15

      Please state the name, telephone number and address of the individuals who were present
with YOU at the time of the INCIDENT.



SPECIAL INTERROGATORY NO. 16

       Had YOU been to the location of the INCIDENT prior to ________________
[Instructions: Insert date of Incident]?



SPECIAL INTERROGATORY NO. 17

      Please describe in detail the reason(s) YOU allegedly injured yourself on
________________ [Instructions: Insert date of injury].



SPECIAL INTERROGATORY NO. 18

     Please describe in detail what type of shoes were YOU wearing at the time of the
INCIDENT.



SPECIAL INTERROGATORY NO. 19

       When was the last time YOU had a ________________ [Instructions: Insert body part
that was injured] examination?



SPECIAL INTERROGATORY NO. 20

        Have YOU ever suffered from a similar injury in the past?




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SPECIAL INTERROGATORY NO. 21

       If YOUR response to the precedent Interrogatory is yes, please state when the injury
occurred.



SPECIAL INTERROGATORY NO. 22

        If YOUR responses to the Interrogatory No. 20 is yes, please describe in detail the nature
of the injury.



SPECIAL INTERROGATORY NO. 23

       Please provide the name, phone number and address of all persons who have knowledge
to support or tend to support YOUR allegation that YOU sustained injuries (physical, emotional
and/or mental) due to the INCIDENT from ________________ [Instructions: Insert date] to
present.



SPECIAL INTERROGATORY NO. 22

     Please state the amount of lost earnings YOU allegedly incurred as a result of the
INCIDENT from the date of the INCIDENT to present.



SPECIAL INTERROGATORY NO. 23

       Please state in detail (including but not limited to the number of days missed, YOUR
daily/weekly/monthly rate of pay at the time, the number of days worked in a month/week)
YOUR method of calculation to arrive at your response to Interrogatory No. 22.



SPECIAL INTERROGATORY NO. 24

      Please provide the names, phone numbers and addresses of all persons who have
knowledge to support or tend to support YOUR response to Interrogatory No. 22.




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SPECIAL INTERROGATORY NO. 25

        Please identify all DOCUMENTS which support or tend to support YOUR response to
Interrogatory No. 22.



SPECIAL INTERROGATORY NO. 26

       Please provide the name, phone number and address of all YOUR employers, in the U.S.
and ________________ [Instructions: Insert any additional countries], for the last ten years.



SPECIAL INTERROGATORY NO. 27

        Please identify all DOCUMENTS which support or tend to support YOUR response to
Interrogatory No. 26.



SPECIAL INTERROGATORY NO. 28

        Please state YOUR job title for each and every employment YOU listed in the
Interrogatory No. 26.



SPECIAL INTERROGATORY NO. 29

        Please state in detail YOUR job duties for each and every employer YOU listed in the
Interrogatory No. 26.



SPECIAL INTERROGATORY NO. 30

        Please state the duration of YOUR employment for the employers listed in the
Interrogatory No. 26.



SPECIAL INTERROGATORY NO. 31

      Please list in detail YOUR wages received, including hourly or salary, for each place of
employment listed in the Interrogatory No. 26.



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SPECIAL INTERROGATORY NO. 32

        Please identify all DOCUMENTS which support or tend to support of YOUR response to
the preceding Interrogatory.



SPECIAL INTERROGATORY NO. 33

       Please state in detail all injuries YOU allege to have sustained due to the INCIDENT,
from ________________ [Instructions: Insert relevant date] to present.



SPECIAL INTERROGATORY NO. 34

       Please provide the name, address and telephone number of the physician(s) that have
diagnosed YOU with the injuries listed in the preceding Interrogatory.



SPECIAL INTERROGATORY NO. 35

        Please identify all DOCUMENTS in support of YOUR response to the Interrogatory No.
33.



SPECIAL INTERROGATORY NO. 36

        Please provide the name, address and telephone number of each and every physician,
including but not limited to chiropractor, therapist, psychologist and psychiatrist, that you visited
due to the INCIDENT, from ________________ [Instructions: Insert date] to present.



SPECIAL INTERROGATORY NO. 37

        Please identify all DOCUMENTS in support of YOUR response to the preceding
Interrogatory.




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SPECIAL INTERROGATORY NO. 38

       Please provide the name, address and telephone number of each and every healthcare
provider YOU visited for medical treatment due to the INCIDENT, from ________________
[Instructions: Insert date] to present.



SPECIAL INTERROGATORY NO. 39

        Please identify all DOCUMENTS in support of YOUR response to the preceding
Interrogatory.

SPECIAL INTERROGATORY NO. 40

       Please state the name, address and telephone number and area of practice of all
physicians, chiropractors, therapists, psychologists and psychiatrists, that YOU visited for
YOUR personal medical care in the past ten years, prior to the date of the INCIDENT.



SPECIAL INTERROGATORY NO. 41

       Please describe in details the reason for YOUR visits with the individuals listed in the
preceding Interrogatory.



SPECIAL INTERROGATORY NO. 42

     Please state the total amount of medical expenses YOU allege to have incurred due to the
INCIDENT from ________________ [Instructions: Insert date] to present.



SPECIAL INTERROGATORY NO. 43

       Please state in details how YOU calculated the amount of YOUR medical expenses in the
precedent Interrogatory.



SPECIAL INTERROGATORY NO. 44

        Please identify all DOCUMENTS in support of YOUR response to the Interrogatory No
42.



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SPECIAL INTERROGATORY NO. 45

     Please state the total amount of medical expenses YOU allege YOU will incur due to the
INCIDENT.



SPECIAL INTERROGATORY NO. 46

      Please state in details how YOU calculated the amount of YOUR future medical
expenses in the precedent Interrogatory.



SPECIAL INTERROGATORY NO. 47

        In the past ten years, have YOU ever consumed any narcotic substance including but not
limited to methamphetamine, cocaine and marijuana?



SPECIAL INTERROGATORY NO. 48

     If YOUR response to the preceding Interrogatory is yes, please list all narcotic substances
YOU have consumed including number of times YOU consumed them.



SPECIAL INTERROGATORY NO. 49

        From ________________ [Instructions: Insert date preceding INCIDENT] to the time
of the INCIDENT, did YOU ingest any non-prescription narcotics such as methamphetamine?



SPECIAL INTERROGATORY NO. 50

        If YOUR response to the preceding Interrogatory is yes, please list all non-prescription
narcotic substance(s) YOU ingested, including number of times YOU ingested them.



SPECIAL INTERROGATORY NO. 51

        From ________________ [Instructions: Insert date preceding INCIDENT] to the time
of the INCIDENT, did YOU ingest any prescribed medication?

© Copyright 2012 Docstoc Inc.                                                                      10
SPECIAL INTERROGATORY NO. 52

       If YOUR response to the preceding Interrogatory is yes, please list the medication(s) by
name and description of the medication(s) that YOU ingested from ________________
[Instructions: Insert date preceding INCIDENT] to the time of the INCIDENT.



SPECIAL INTERROGATORY NO. 53

        If YOUR response to the Interrogatory No. 51 is yes, please state how long YOU were
taking the medication(s) listed in Interrogatory No. 51.



SPECIAL INTERROGATORY NO. 54

        From ________________ [Instructions: Insert date preceding INCIDENT] to the time
of the INCIDENT, did YOU ingest any non-prescription/over-the-counter medication, including
but not limited to common cold medication?



SPECIAL INTERROGATORY NO. 55

       If YOUR response to the preceding Interrogatory is yes, please list the medication(s) by
name and description of the medication(s) that YOU ingested from ________________
[Instructions: Insert date preceding INCIDENT] to the time of the INCIDENT.



SPECIAL INTERROGATORY NO. 56

        If YOUR response to the Interrogatory No. 54 is yes, please state how long YOU were
taking the medication(s) listed in Interrogatory No. 54.



SPECIAL INTERROGATORY NO. 57

       Prior to INCIDENT, have YOU ever suffered from any condition or illness that caused or
can cause loss of consciousness?




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SPECIAL INTERROGATORY NO. 58

       If YOUR response to the Interrogatory No. 57 is yes, please state when each incident
occurred.



SPECIAL INTERROGATORY NO. 59

      If YOUR response to the Interrogatory No. 57 is yes, please state the reason for each time
YOU lost consciousness.



SPECIAL INTERROGATORY NO. 60

      If YOUR response to the Interrogatory No. 57 is yes, please state the name, telephone
number and address of the doctors that treated YOU for this condition.



SPECIAL INTERROGATORY NO. 61

        If YOUR response to the Interrogatory No. 57 is yes, please state if YOU were and still
are taking any medication for YOUR condition.



SPECIAL INTERROGATORY NO. 62

       If YOUR response to the Interrogatory No. 57 is yes, please state if to date YOU still
experience the same condition?



SPECIAL INTERROGATORY NO. 63

       Prior to the date of the INCIDENT, have YOU ever been diagnosed with or suffered from
a condition that causes dizziness or loss of balance?



SPECIAL INTERROGATORY NO. 64

       If YOUR response to the preceding Interrogatory is yes, please describe in detail the
condition/diagnosis?



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SPECIAL INTERROGATORY NO. 65

       If YOUR response to the Interrogatory No. 63 is yes, please state how often YOU
experience dizziness or loss of balance?



SPECIAL INTERROGATORY NO. 66

      If YOUR response to the Interrogatory No. 63 is yes, please state the name, telephone
number and address of the doctors that treated YOU for your dizziness or loss of balance.



SPECIAL INTERROGATORY NO. 67

          Please state in detail each and every item of special damages YOU are claiming in this
matter.



SPECIAL INTERROGATORY NO. 68

       Please identify each and every DOCUMENT which supports or tends to support YOUR
response to the preceding Interrogatory.



SPECIAL INTERROGATORY NO. 69

          Please describe in detail YOUR relationship with the Defendant.



SPECIAL INTERROGATORY NO. 70

          On the date of the INCIDENT, was the defendant present?



SPECIAL INTERROGATORY NO. 71

          Please state in detail all YOUR contact with Defendant on the date of the INCIDENT.




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SPECIAL INTERROGATORY NO. 72

      Please state in detail all facts supporting YOUR allegation in YOUR Complaint that
Defendant ________________ [Instructions: Insert allegation in complaint].



[Comment: User should repeat this question for every allegation of plaintiff.]



SPECIAL INTERROGATORY NO. 73

        Please list all medications prescribed to YOU from the date of the INCIDENT to present
due to the alleged INCIDENT.



SPECIAL INTERROGATORY NO. 74

        Please state in detail all locations where YOU obtained or refilled your medications listed
in the preceding Interrogatory, from the date of the INCIDENT to present.



SPECIAL INTERROGATORY NO. 75

      Please state the name, address and telephone number of all physicians that prescribed the
medications YOU listed in the Interrogatory No. 73.

Dated: ________________ [Instructions: Insert date]



________________ [Instructions: Set forth attorney’s name]

Attorneys for Defendant

________________ [Instructions: Set forth name of Defendant]




[Comments: User should attach a proof of service with this request for production of
documents]


© Copyright 2012 Docstoc Inc.                                                                    14

				
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Description: This Personal Injury Interrogatories to Plaintiff document sets forth many of the special interrogatories that should be propounded on a plaintiff in a personal injury case. Interrogatories are an integral part of conducting discovery, and this document will help ensure that no information is overlooked. The propounding party can easily insert specific terms into this document to make sure the end result is tailored to the party's unique situation. This document should be used by defendants or their attorneys when conducting discovery in a personal injury case.